OSHA Update2015

Jim Lutz Milwaukee Area OSHA OfficeAugust 2015

Topics

What’s New? Regulatory Agenda Initiatives and Emphasis for

2015 Inspections and Inspection

Data Frequently Cited Standards Resources

New OSHA TopicsUpdates to OSHA’s Recordkeeping and Reporting Rule

OSHA has expanded the list of severe injuries & illnesses that employers must report & updated the list of industries who are partially exempt from routinely keeping OSHA records.

The Final rule became effective January 1, 2015 for workplaces under Federal OSHA jurisdiction.

Expanded Reporting Requirements

The rule expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA.Starting January 1, employers must report the following to OSHA: All work-related fatalities within 8 hours

(same as current requirement) All work-related in-patient hospitalizations

of one or more employees within 24 hours All work-related amputations within 24 hours All work-related losses of an eye within

24 hours

Expanded Reporting Requirements

• If the injury or illness resulted in a fatality, hospitalization, amputation or loss of an eye, report to OSHA.

• If you are in an industry covered by OSHA’s updated recordkeeping requirements, also make a record of the injury or illness in the OSHA 300 Log.

By telephone to the nearest OSHA office during normal business hours.

By telephone to the 24-hour OSHA hotline (1-800-321-OSHA or 1-800-321-6742).

Online: OSHA is developing a new means of reporting events electronically, which will be available soon at www.osha.gov/report_online.

How can Employers Report to OSHA?

OSHA’s Spring 2015

Regulatory

AgendaAvailable at Reginfo.gov

Walking/Working Surface – SubPart D

Silica Electronic Recordkeeping

From WashingtonRegulatory Agenda

Current Focus

Sub-Part D - Walking Working Surfaces

Proposed

General Industry Walking-Working Surfaces: prescribes the use of fall protection systems to protect employees from falls. Performance-oriented standard

• 15 new ANSI standards being cited• are designed to eliminate detailed specifications

and facilitate compliance• Proposed paragraph (a)(2) requires that each

employee be trained by a qualified person on the nature of

hazards and protective methods• Includes walking/working

surfaces such as rolling stock (trucks)

Silica Rule Workers can become ill if they

inhale respirable crystalline silica

Proposed

• Respirable particles are very small (1/100th the size of a grain of sand)

• Can penetrate deeply into the lungs

• Can’t be seen or smelled and must be measured using air sampling equipment

Silica Rule

Establishes new PEL of 50 μg/m3

Includes provisions for: Measuring worker exposures to silica; Limiting access to areas where workers

could be exposed above the PEL; Use of dust controls; Use of respirators when necessary; Medical exams for highly exposed workers; Worker training; and Recordkeeping.

Proposed

Electronic Recordkeeping Rule

New Recordkeeping Rule will require employers to: • Submit specific injury and illness data

electronically;• On a quarterly or annual basis;• Data will be posted in an online publicly

searchable database. Under the rule, establishments with 250 or more employees will be required to submit injury and illness records on a quarterly basis to OSHA. 

Establishments with 20 or more employees in industries with high injury and illness rates (construction), will be required to submit a summary of their work-related injuries and illnesses electronically once a year.

Proposed

Updated Beryllium Standard

Proposed

OSHA’s eight-hour permissible exposure limit for beryllium is 2.0 micrograms per cubic meter of air. Above that level, employers must take steps to reduce the airborne concentration of beryllium. OSHA’s proposed standard would reduce the eight-hour permissible exposure limit to 0.2 micrograms per cubic meter. The proposed rule would also require additional protections, including personal protective equipment, medical exams, other medical surveillance and training.

Workers exposed to beryllium are in foundry and smelting operations,

machining, beryllium oxide ceramics and composites manufacturing and dental

lab work.

What Became Long-Term Action

Injury and Illness Prevention Program Combustible Dust Rulemaking Backover Rules

HazCom 2012 Implementation Phase

The major change is a switch from performance oriented requirements to specific requirements.

Former

Hot Topic

OSHA Briefs/Compliance Guide

Confined Spaces in Construction

What’s New?

Subpart AA – OSHA Construction Standards

Why do we have a new standard?

Confined space hazards have led to numerous worker deaths:• A worker lost consciousness, fell, and was

killed while climbing down a ladder into an unventilated underground valve vault to turn on water valves.

• A worker who lost consciousness and died when he climbed into a sewer vault to retrieve a tool. His co-worker also died when he attempted a rescue.

• While repairing a natural gas leak, a worker entered a drainage pipe to retrieve survey equipment. The natural gas ignited, killing the worker.

Subpart AA Scope

Subpart P still covers work in excavations If there is a confined space within an excavation,

such as a sewer pipe, and a worker enters the pipe to perform work, that is covered by Subpart AA

Subpart S still covers underground construction Work done in an underground space that does not

involve altering the *structure* of the space is covered by Subpart AA (such as equipment installs)

Subpart AA Scope• GI Standard, Plus• A competent person must conduct

worksite evaluation• Employers using “alternate

procedures” for permit space entry must prevent physical hazard exposures through elimination or isolation through methods such as LOTO

• Permits may be suspended instead of cancelled, provided the space is returned to permit conditions prior to re-entry

Subpart AA Scope, continued

Continuous monitoring of atmospheric and engulfment hazards

Employers relying on local emergency services for rescue must arrange for responders to notify in advance if local responders will be unavailable

Specific information exchange requirements for multi-employer work sites

Multi-Employer WorksitesThe Controlling Contractor, rather than the Host Employer, is the primary point of contact for information about permit spaces at the work site. The Host Employer must provide information it has about permit spaces at the work site to the Controlling Contractor, who then passes it on to the employers whose employees will enter the spaces (Entry Employers).

Definitions Confined Space:

Is large enough for a worker to enter it; Has limited means of entry or exit; and Is not designed for continuous

occupancy. Permit-Required Confined Space:

has a hazardous atmosphere, the potential for engulfment or suffocation, a layout that might trap a worker through converging walls or a sloped floor, or any other serious safety or health hazard.

Confined Space Hazards Atmospheric (respirable) hazards, such as

hydrogen sulfide, carbon monoxide, low oxygen, excessive oxygen, and other toxic gases and particulates

Explosive hazards, including flammable gases in concen- trations above 10% of the lower explosive limit (LEL), combustible dusts, and other explosive/flammable materials

Physical hazards, including tripping hazards, fall hazards, struck-by hazards, and electrical hazards

Don’t Forget Biological Hazards

What are Employers Responsible for?

Employers must determine whether confined spaces exist at the work site.

Under the construction rule, a competent person must identify all confined spaces.

The competent person must also identify all permit spaces – those workers who will enter, and those that will not. All permit spaces must be posted/identified in some way.

What must employers do? cont'd

Next, an employer who has determined that workers will perform work in permit spaces must develop a permit space program. Appendix C - Examples of Permit-Required Confined Space Programs

If workers will not perform work in permit spaces, the employer must ensure that the workers are prevented from entering the permit spaces.

What is a Permit Space Program?

A Permit Space Program is a plan that includes:

Identification and evaluation of the hazards in the permit

space Measures that will be used to

prevent unauthorized entry Means, procedures, and

practices needed for safe entry, including: …

Permit Space Program Specify acceptable entry conditions,

including but not limited to; Atmospheric conditions such as oxygen levels,

explosive substance limits, toxic substance limits When and how the employer will provide

each authorized entrant or their representative the chance to observe monitoring or testing of permit spaces;

How the employer will isolate the permit space and physical hazards within the space, if needed;

Program Elements, cont'd

Whether and how the employer will purge, inert, flush, or ventilate the permit space to eliminate or control atmospheric hazards;

Specify the use of a monitoring system or procedures that will detect hazardous changes in atmospheric conditions in time for entrants to safely exit the space;

Discuss the barriers that will be used to prevent entrants from external hazards and unauthorized entry;